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Goldberg v. Kelly

Supreme Court of the United States

October 13, 1969, Argued ; March 23, 1970, Decided

No. 62

Case Summary

Procedural Posture

Appellant commissioner of social services sought review of a decision of the United States District Court for the Southern District of New York, which ruled in favor of appellee welfare recipients. The district court held that before welfare benefits could be terminated, only a fair prior evidentiary hearing satisfied due process requirements.

Overview

The Supreme Court affirmed the determination of the district court that only a fair hearing prior to termination of welfare benefits satisfied due process. The procedures used by the commissioner in terminating welfare benefits required notice of termination and a review by a local welfare official, allowed a recipient to make a written statement to demonstrate why benefits should not be terminated, and further allowed a fair hearing after termination. On review the Court held that a pre-termination evidentiary hearing to produce an initial determination of the validity of the termination was necessary to satisfy procedural due process. The Court found that especially with welfare recipients who lacked independent resources, termination of benefits while the issue was being decided deprived recipients of the very means necessary to live. The Court noted that the need to concentrate upon finding the means for daily subsistence adversely affected the ability to seek redress from the termination, and the protection of due process outweighed the expense of a pre-termination hearing and continued benefits pending decisions.

Outcome

The district court's determination that failure to provide a fair hearing prior to the termination of welfare benefits failed to satisfy procedural due process was affirmed. The Court held that termination of benefits prior to a fair hearing adversely affected a recipient's ability to seek redress.

LexisNexis® Headnotes

 

 

Governments > Legislation > Statutory Remedies & Rights

Public Health & Welfare Law > Social Security > Assistance to Families > General Overview

HN1  Legislation, Statutory Remedies & Rights

Welfare benefits are a matter of statutory entitlement for persons qualified to receive them. Their termination involves state action that adjudicates important rights.

 

Labor & Employment Law > Disability & Unemployment Insurance > Unemployment Compensation > Benefit Entitlements

Public Health & Welfare Law > Social Security > Assistance to Families > General Overview

Constitutional Law > ... > Fundamental Rights > Procedural Due Process > Scope of Protection

Labor & Employment Law > Disability & Unemployment Insurance > General Overview

Labor & Employment Law > ... > Unemployment Compensation > Eligibility > General Overview

HN2  Unemployment Compensation, Benefit Entitlements

Relevant constitutional restraints apply as much to the withdrawal of public assistance benefits as to disqualification for unemployment compensation, or to denial of a tax exemption, or to discharge from public employment. The extent to which procedural due process must be afforded the recipient is influenced by the extent to which he may be condemned to suffer grievous loss, and depends upon whether the recipient's interest in avoiding that loss outweighs the governmental interest in summary adjudication. Consideration of what procedures due process may require under any given set of circumstances must begin with a determination of the precise nature of the government function involved as well as of the private interest that has been affected by governmental action.

 

Administrative Law > ... > Formal Adjudicatory Procedure > Hearings > General Overview

Constitutional Law > ... > Fundamental Rights > Procedural Due Process > Scope of Protection

Public Health & Welfare Law > Social Security > Assistance to Families > General Overview

HN3  Formal Adjudicatory Procedure, Hearings

When welfare is discontinued, only a pre-termination evidentiary hearing provides the recipient with procedural due process.

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397 U.S. 254 ; 90 S. Ct. 1011 ; 25 L. Ed. 2d 287 ; 1970 U.S. LEXIS 80 

GOLDBERG, COMMISSIONER OF SOCIAL SERVICES OF THE CITY OF NEW YORK v. KELLY ET AL.

Prior History:  [1]  APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK.

Disposition:  294 F.Supp. 893, affirmed.